Pan American Health Organization Regional Office of the World Health Organization

Pan American Health Organization
Regional Office of the World Health Organization
Division of Vaccines and Immunization
IMMUNIZATION
SAFETY
How to address events
allegedly attributable to
vaccination or immunization?
Washington, DC, United States
Document prepared by the Working Group on Immunization Safety
Division of Vaccines and Immunization.
ISBN 92 75 324042
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(c) Pan American Health Organization, 2002
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Contents
1. Purpose
2. Introduction
3. Vaccine Quality and Safety
4. Rates of Events Attributed to Vaccination or Immunization
a.
Common mild events
b.
Rare and severe events
c.
Operational errors in the program
5. Investigation of Events Allegedly Attributable to Vaccination or Immunization
a.
Stages of the investigation
b.
Information and investigation
c.
Steps to be taken
6. Event Reduction during Vaccination Campaigns
a.
Measures to prevent ESAVI during the campaigns
7. Management of Crisis Situations
a.
What is a crisis?
b.
Why does a crisis arise?
c.
Four steps for the management of ESAVI and prevention of crises
8. Communication and Information on Vaccination and Immunization Safety
a.
Relations with the communications media
b.
What is the perspective of the mass media?
c.
How to give an interview or a press conference
d.
Sixteen pieces of advice on style
f.
Skills
9. Summary of Vaccines, Diseases They Prevent, and Disease Effects
10. Bibliographic References
3
01.
Purpose
In order to maintain or improve confidence in national immunization programs, workers
in the health sector, from the local level up to the central level of the Ministry of Health,
should be familiarized with all aspects of vaccination; furthermore, they should be
prepared to respond to any concerns of the population. Rapid response to public concern
about vaccines, as well as immediate and clear communication of explanations and
actions, will preserve the integrity of the immunization program.
The purpose of this document is to provide health workers with principles and procedures
that should be followed in addressing concerns about vaccination risks. Proper
implementation of this guide will aid in the acquisition of additional information on
possible events allegedly attributable to vaccination or immunization (ESAVI). These
data should be complemented with the information compiled in other analytic studies,
such as clinical trials, thus maintaining confidence in the national immunization program.
It is hoped that this document will assist health workers in establishing adequate
mechanisms for:
•
•
•
•
•
•
02.
determining the quality and safety of vaccines;
knowing the rates of events that may be related to vaccines;
reporting, investigating, and analyzing the events that are supposedly related to
vaccines;
taking steps to solve any problem identified in the investigation and to face any
crisis;
communicating efficiently and effectively with the community and with the
communications media;
reporting to parents on the events related to vaccines and on the diseases against
which they provide protection.
Introduction
One of the greatest achievements in public health has been infectious disease prevention
through immunization. Few interventions in this field that have prevented as many deaths
and diseases as vaccinations administered through organized immunization programs.
Although the discovery and introduction of vaccines occurred at the end of the 18th
century, the surprising potential of vaccines was not truly recognized until 1977, when
the eradication of smallpox was achieved.
Based on the lessons learned from the efforts to eradicate smallpox, other campaigns
have been implemented in the Americas for the eradication of poliomyelitis and measles.
As a result of the steadfast commitment to immunization on the part of health workers
and parents, the last case of poliomyelitis in the Americas caused by the wild virus was
recorded in Peru in August 1991. Furthermore, throughout the world the campaigns to
eradicate it by 2005 continue. Measles transmission has been slowed after several years
4
of resurgence in Latin America. Campaigns are currently under way for its eradication,
and there is also a strong commitment to measles control elsewhere in the world.
Despite significant progress in disease control, however, immunization is not free of
controversy, and so the world has witnessed the dangers and effects of the interruption of
vaccination. In the United Kingdom, public concern over the risks associated with
whooping cough vaccines during the 1970s led to a reduction in vaccination coverage,
which had been higher than 80% with 2,000-8,000 cases reported annually. When the
coverage declined to 30%, the number of cases of whooping cough rose precipitously to
over 100,000, resulting in deaths and hospitalizations that could have been avoided. After
two major epidemics and a number of campaigns to educate the population about the
disease and the vaccine, confidence in the vaccine and the immunization programs slowly
recovered. Coverage rose to 95% by the middle of the decade and as a result, the lowest
number of cases of whooping cough in the history of the United Kingdom was recorded
(see Figure 1).
Figure 1
Incidence of Whooping Cough in Countries Affected by Active
Movements against the Vaccines - England and Wales
Introduction of
DTP
Active MAV
500
DTP
Introduced
93%
93%
81%
Incidence per 100,000
Cases per 100 000
400
81%
Vaccine Uptake
300
Coverage of
31% the vaccine
200
31%
100
0
1940
1940
1950
1950
1960
1970
1960
1970
1980
1980
1990
1990
Year
Year
Source: Gangarosa. Lancet 351, 1998
5
Every immunization program should endeavor to make vaccination risk-free.
Furthermore, those in charge should address any cause for concern that arises in the
population about the safety of immunization, for example the effects observed during
clinical trials prior to the issuing of licenses or during the experimental stages of a
vaccine's development.
The first years of a child's life constitute the period of greatest vulnerability to diseases
and of the first manifestations of other problems (developmental disorders, hearing
impairments, and others). It is precisely during that period that vaccines are administered
and are interpreted as causal, although in many cases it is difficult to determine the true
cause of the problem.
The technology continues to improve with time, as do the quality and effectiveness of the
vaccines utilized. Although vaccines are now much safer than they were 40 years ago,
every year new ones enter the market and information proliferates on the Internet, leading
to the proliferation of the population's concerns about risks and benefits. Hence,
immunization programs have a responsibility to address these concerns.
03.
Vaccine Quality and Safety
All vaccines obtained through the World Health Organization (WHO) for national
immunization programs have met the following requirements:
•
•
•
examination of their characteristics
adherence to the standards of good manufacturing practices, and
approval by the national regulatory authority (NRA).
WHO certifies that a vaccine is of good quality if the NRA determines the quality of the
vaccine, based on the six essential functions required of the producing laboratories; they
must:
•
•
•
•
•
•
Publish a set of clearly written licensing requirements (for products and
manufacturers) and ensure compliance.
Present an analysis of the results of the use of the vaccine in the field (safety and
effectiveness).
Have a system for lot release.
Present laboratory test results, if necessary.
Permit regular inspections to confirm adherence to the standards of good
manufacturing practices.
Evaluate clinical results through authorized clinical trials.
Before a license is granted, in order to meet the conditions required for registry, the
safety and effectiveness of each vaccine must be demonstrated in clinical trials,
conducted in different phases under controlled conditions.
6
The performance of the essential functions varies. In countries where the vaccines are
produced, the NRA should require the performance of the six functions listed above. In
countries that obtain vaccines through United Nations agencies (in the Region of the
Americas vaccines are purchased through the PAHO/WHO Revolving Fund), the NRA
are responsible for the following functions:
•
•
•
Registration of vaccines.
Postmarketing surveillance (follow-up study on effectiveness and postvaccination
events).
Release of lots of vaccines by:
–
–
–
document analysis (protocols and certificates of release from internal
control that describe in detail the production process and the NRA in the
producing country)
laboratory tests, or
both.
After the license is granted and the vaccine is administered to the population, follow-up
studies of the vaccines are conducted (postmarketing surveillance). This monitoring
provides information on the effectiveness of the vaccine, which, if properly
communicated, can contribute valuable knowledge to the vaccination profile.
The existence of many events that are supposedly related to a given vaccine indicate that
there may be a problem with its application (program operation errors), such as
contamination, improper injection, problems in the cold chain, dosage errors, or dilution
or administration of vaccines as though they were drugs. These problems can be
corrected easily through the training and supervision of health workers and proper
handling and storage techniques. It is imperative that each local health worker be aware
of these potential problems and recognize them when they occur, so that they are
corrected immediately.
In the following section mild and severe events are listed by type of vaccine. The events
allegedly attributable to the vaccination or immunization vary with respect to their
severity and frequency.
04.
Rates of Events Attributed to Vaccination or Immunization
a. Common mild events
The purpose of a vaccine is to induce immunity (to form antibodies) through the reaction
of the immune system of the vaccinated person. It is not surprising that vaccines generate
certain mild side effects. A local reaction, fever, and general symptoms may be part of
the normal immune response. Furthermore, some of the components of the vaccine (for
example, the aluminum adjuvant, antibiotics, or preservatives) may produce reactions. An
effective vaccine minimizes these reactions, while at the same time inducing maximum
7
immunity. The local reaction (at the injection site) is characterized by pain, swelling, or
reddening. Presentation of symptomatic local reactions and fever is anticipated in nearly
10% of vaccinated individuals, except in the case of DTP or TT boosters, which produce
fever in nearly half of those vaccinated.
BCG vaccination often causes a delayed local reaction that begins in the second week. It
is a papule (light elevation in the skin) that becomes ulcerated and heals after several
months. The keloid (rough enlarged scar) that BCG may leave is more common in Asian
and African populations.
Summary of the rates of mild events attributed to vaccination or immunization
Vaccine
Hib (Haemophilus
influenzae type b)
Hepatitis B
Local reaction (Pain,
swelling and symptoms
not reddening)
5-15%
up to 30% in adults
up to 5% in children
up to 10%
none
Fever
Irritability, discomfort
and symptoms not
2-10%
-
1-6%
-
Measles/MMR
up to 5%
up to 5%
Oral polio vaccine
less than 1%
less than 1% a)
(OPV)
TT/DT
up to 10% b)
up to 10%
up to 25%
DTP c)
up to 50%
up to 50%
up to 60%
BCG d)
Common
(Note: The rates corresponding to the administration of the vaccines will be lower,
because these symptoms occur normally in childhood, without vaccines).
a)
b)
c)
d)
Diarrhea, headache, and muscle pain.
It is probable that the rates of local reactions increase by 50 to 85% with the booster dose.
For whole-cell whooping cough vaccine. The rates for acellular whooping cough vaccine are
lower.
Local reactogenicity varies from one vaccine to another, depending on the strain and the number
of viable bacilli.
These common reactions appear one or two days after the administration of the vaccine,
except for the fever and general symptoms produced by measles/MMR vaccine 5 to 12
days after vaccination. Although some 5% to 15% of those receiving measles/MMR
vaccine present fever and exanthema during this time, only around 3% of the cases are
attributable to the vaccine; the rest correspond to normal reactions in infancy, that is, to
ordinary events.
b. Rare and severe events
Almost all rare vaccinal reactions (for example, convulsions, thrombocytopenia, episodes
of hypotonia and hyporeactivity, and inconsolable persistent crying) are characterized by
spontaneous remission and do not lead to subsequent problems or sequelae. Although
8
anaphylaxis can be fatal, it leaves no aftereffects if treated in a timely manner, and while
encephalopathy is cited as a rare reaction to measles and DTP vaccines, in reality a causal
relationship has not been demonstrated. Uncommon mild events are detailed in the
following table:
Summary of Severe Events Attributed to the Vaccination or Immunization.
Time They Take to Appear and Rates.
Vaccine
BCG
Hib
Hepatitis B
Measles
/MMRa)
Oral polio vaccine
(OPV)
TT/DT
DTP
Yellow fever
Event
Time they
take to
appear
Rates per
1,000,000
doses
Suppurative lymphadenitis
Osteitis from BCG (“BCGitis”)
“BCGitis” spread by the BCG vaccine
Unknown
Anaphylaxis
Guillain-Barré syndrome (vaccine obtained in
plasma) *
Febrile convulsions
Thrombocytopenia (low platelet count)
Anaphylaxis
Vaccine-associated paralytic poliomyelitis (VAPP)
2-6 months
1-12 months
1-12 months
0-1 Hour
0-6 weeks
100-1,000
1-700
2
1-2
5
5-12 days
15-35 days
0-1 hour
4-30 days
333
33
1-50
1,4-3,4b)
Neuritis of the brachial plexus
Anaphylaxis
Sterile abscess
Persistent crying that lasts more than 3 hours
Convulsions
Episode of hypotonia and hyporreactivity (EHH)
Anaphylaxis
Encephalopathy
2-28 days
0-1 hour
1-6 weeks
0-24 hours
0-2 days
0-24 hours
0-1 hour
0-3 days (to
level)
7-21 days
5-10
1-6
6-10
1,000-60,000
570c)
570
20
0-1
Encephalitis subsequent to vaccination
Allergic/anaphylaxis reaction
0-1 hour
500-4,000 in less
than 6 m
5-20
a) There is no reaction (except for anaphylaxis) when there is immunity (~90% of those who receive a second dose);
febrile convulsions are unlikely in children older than 6 years.
b) The risk of VAPP is higher with the first dose (1 in 1,400,000–3,400,000 doses) than with subsequent doses and
contacts, 1 per 5,900,000 and 1 per 6,700,000 doses, respectively.
c) The convulsions are chiefly febrile in origin, and the rate depends on the personal and family history and the age,
with a lower risk in infants under 4 months.
d) The isolated cases without a denominator hinder evaluation of the rate in older children and adults but are very rare
(less than 1 case per 8,000,000 doses).
* The vaccine used in Peru is recombinant.
c. Program operation errors
Most reactions that are cited, whether “common and mild” or “rare and severe”, are
difficult or impossible for the vaccinator to prevent. Nevertheless, there is one type of
event that the vaccinator can prevent to a large extent. It concerns the “program operation
error.” This error is more frequently human than caused by the vaccine or the technology.
9
It can usually be prevented through training for personnel, supervision, and an adequate
supply of equipment for safe injection.
A program operation error may lead to a cluster of events, especially if a vaccinator does
not follow what he was taught during training. Improper vaccination practices can give
rise to abscesses or other blood-borne infections. The most serious result is toxic shock
caused by improper handling of the vaccine vial after reconstitution. Several infants
vaccinated from the same vial could die shortly after injection.
Operational Program Errors and their Consequences
Operational Program Error
Non-sterile injection:
• Recycling of a syringe or disposable needle.
• Use of syringes that do not ensure adequate
sterility.
• Contaminated vaccine or dilutant.
• Utilization of lyophilized vaccines longer than
indicated time of use.
Reconstitution error:
• Reconstitution with the wrong dilutant.
• Replacement of the vaccine or dilutant with a
drug.
Injection in the wrong place:
• BCG administered subcutaneously.
• DTP/DT/TT administered too superficially.
• Injection in the buttock.
Improper transport/storage of vaccines.
Ignoring of contraindications.
Anticipated Event
•
Infection, as a localized abscess at the injection
site, sepsis, toxic shock syndrome, or death.
Blood-borne infection, such as hepatitis or
HIV.
•
•
•
•
Local abscess due to insufficient agitation.
Adverse effect of a drug--for example, insulin.
Death.
Ineffective vaccine.
•
•
•
•
•
•
Reaction or local abscess.
Reaction or local abscess.
Injury to the sciatic nerve.
Local reaction due to frozen vaccine.
Ineffective vaccine*.
Serious reaction foreseeable.
The information in this section serves for:
•
Anticipating events for specific biologicals (type and number).
•
Detecting events unrelated to vaccines (for example, unanticipated events).
•
Comparing reported rates with expected rates (efficiency of the reporting).
•
Launching an investigation if the reported rate exceeds the expected rate.
05.
Investigation of Events Supposedly
Attributable to Vaccination or Immunization (ESAVI)
It is difficult to determine if an event allegedly attributable to vaccination or
immunization (ESAVI) is really the result of the administration of the vaccine and the
subsequent immunization, especially in small children. On the one hand, in this age group
many events that are attributed to vaccines occur with a certain frequency, and it is
10
difficult to distinguish between an event related to the administration of the vaccine and
the natural occurrence of the incident.
Every event that the public, parents, the patient, or health workers consider related to a
vaccine should be investigated at the local level. If the suspicion is justified (that is, the
timing and the symptoms indicate the possibility of a connection to the vaccine), a more
formal, standardized investigation should be initiated immediately, with regional and/or
national support.
The purpose of the investigation is to confirm or rule out the vaccine as the cause of the
reported event, to determine whether there are other possible causes, to confirm whether
this is an isolated event, and to inform the parties involved.
a. Stages of the investigation
Initial evaluation: As soon as any ESAVI is recognized, the health worker should
inform the parents or guardians that immunization is safe, give them confidence, and
explain to them that there can be simultaneous events that are not necessarily due to the
vaccine.
There should be an investigation of any serious event (one that endangers life or
causes disability, hospitalization, or death), rumors, or events which occur in groups
of people.
Until the investigation is completed, it is impossible to determine the causes of the event.
These may be related to operational aspects of the program or to the vaccine, unrelated to
the vaccine, or of unknown etiology. In some situations, external tests may be necessary
to identify the cause.
b. Information and investigation
1. The investigation should begin within the first 24 hours.
2. The first step in the investigation is to make a detailed examination of the following
•
•
•
•
•
program refrigerator
work table
vaccination room
place where syringes are stored
list of drugs that are received and delivered to the health services (to review the
flow of drugs).
3. The general data to be collected in the investigation are indicated below:
11
•
Basic information that should be gathered:
9 Demographic data: age, sex, place of residence.
9 Family history.
9 Recent clinical summary (symptoms and signs, when they appeared, duration,
clinical examination, auxiliary diagnostic tests, treatment, course).
9 Type of event, date of appearance, duration, and treatment of the clinical event.
9 Pathological and clinical history of the patient (at birth, previous reactions to
vaccines, allergies to certain pharmaceutical preparations, preexisting
neurological disorders, sleep apnea, drugs currently taken, etc.).
9 Vaccination history: type of vaccine utilized and date of the last dose, type of
previous reaction (if any).
9 Housing and socioeconomic conditions, shelter, type of bed, and sleeping habits.
9 In the event of death, a description of how the body was found, position,
temperature, type of secretion (if any) from the mouth or nostrils.
9 Full autopsy report, toxicological screening, and pathological anatomy.
•
9
9
9
9
9
9
9
Identification of the vaccine and syringe utilized:
Lot number.
Dates of manufacture and expiration.
Manufacturing laboratory.
Origin of the vaccine/syringe, date of shipment and data of transport.
Physical appearance of the vaccine/syringe.
Results of the procedures to control vaccine quality.
Review of the production protocol of the implicated vaccine.
9
9
9
9
9
9
9
9
9
9
9
Review of operational aspects of the program:
Vaccine storage.
Handling and transport of vaccines.
Use of dilutants, reconstitution of vaccines, and forms of administration.
Proper dosages.
Availability of needles and syringes, and appropriate practices.
Circumstances and the way vaccination is administered.
Health care practices in the health services.
Person who administered the vaccine.
Technique for administration.
Order of administration of the dose from the vial.
Cold chain.
•
•
•
Monitoring of other children vaccinated with the same vial and/or lot.
Determination of whether the reported event is an isolated incident or the same or
similar symptoms occurred in one or more of the following:
9 Population vaccinated with the same lot of vaccine in the same period.
9 Unvaccinated population.
12
9 Population vaccinated with a different vaccine lot (from the same manufacturer or
another one).
4. For investigation of severe events, such as deaths allegedly attributable to the
vaccination or immunization, it is recommended that the autopsy be performed within the
first 72 hours, following the procedure below:
•
•
•
•
If the child dies at home with no evident cause, upon its arrival at the health
facility the physician should undertake a detailed verbal autopsy with the mother,
take a clinical history, and examine the body externally in search of signs of
disease, such as jaundice (yellow staining of skin and sclerae), petechiae,
cyanosis, or pallor.
If possible, x-ray the body.
Coordinate with the autopsy department of each jurisdiction for:
a.
Perform of the autopsy as soon as possible to avoid tissue lysis (in the
adrenal glands, for example), which can hinder diagnosis. During this
process the autopsy form is filled out, which will aid the forensic expert by
providing the patient's history.
b.
Sampling for toxicological screening, providing 80 to 100 g of liver, 80 to
100 g of brain, and the stomach contents. If there are no gastric contents, a
section of stomach should be sent. All the samples will be sent together in
a wide-mouthed bottle with no additives (without formalin or other
additional substance). For preservation use only cold packs.
c.
Sampling for pathological anatomical examination, providing 3 to 4 cm of
each organ: for example, a fragment of the brain with meninges, a
fragment of each of the 5 lobes of the lung, fragments from both adrenal
glands (located on the kidneys), as well as from any other organ in which
pathologies are suspected. In each case, the sample will be representative
of the suspicious area. The specimens are to be sent together in a widemouthed bottle, with sufficient formalin to cover all the pieces.
d.
Both sets of samples should be sent to the reference laboratory for
thanatological and auxiliary examinations. All the samples should be
labeled with the name and autopsy form number and be accompanied by
the documents requesting the examination and investigation, and the
conclusions from the autopsy, which should list the cause of death,
utilizing ICD 10, and, if possible, the causative agents. The epicrisis of the
CH should be added.
The reference laboratory for thanatological and auxiliary examinations will send
the results to the immunization program of the Ministry of Health.
5. When ESAVI occur unexpectedly or at unexpected rates, samples will be collected
from the compromised vaccine lots for reevaluation of the quality control of each of
them.
After the investigation, the information should be analyzed to determine the cause,
confirm the diagnosis, or suggest other possible diagnoses.
13
c. Steps to be taken
The steps to be taken will be based on the conclusions of the investigation, which will
have one of the following results:
1)
2)
3)
The event is definitively not related to the vaccination.
The event is related to the vaccination.
•
It is related to the operational aspects of the program.
•
It is related to the vaccine.
The investigation is not conclusive.
When the investigation is finished and the results obtained, they should be reported to the
interested parties. To this end, clear communication will be necessary, and the
information should be disseminated to the parents, the community, and the Region, and,
at the center, to the health authorities, professional associations, or the entire country,
including the mass media, when appropriate.
Conclusions from the investigation
1.-The event is definitively not related to the vaccination.
Some clinical cases simply coincide with the vaccination; that is, the event might have
occurred even if the person had not received the vaccine. The best way of sustaining the
argument that the event is simply coincidental to the vaccination is to demonstrate that
the same event also occurred in a population group that was not immunized.
Although the ESAVI has not been linked to the vaccination, it may require adequate
medical monitoring, and thus a mechanism for referral to the necessary health services
should be established.
2.-The event is related to the vaccination.
• Related to the operational aspects of the program
That is, when the events are caused by one or more of the following errors:
9 Inadequate dosage.
9 Incorrect method of administration.
9 Unsafe use of needle and disposable syringe.
9 Failure to verify the condition of the packaging that guarantees the sterility of
needles and syringes.
9 Improper handling of needles and syringes.
9 Reconstitution of the vaccines with the wrong dilutant.
9 Improper quantity of dilutant.
9 Improper preparation of vaccines.
14
9
9
9
9
9
Substitution of vaccines or dilutants with drugs or other substances.
Contamination of the vaccine or the dilutant.
Improper storage of the vaccines and syringes.
Vaccines and syringes used after their expiration date.
The errors cited thus far are program operation errors.
What should be checked?
9 Whether several cases occur and whether the same health worker administered
the vaccines.
9 Whether the unimmunized population in the same age group and the same
geographical area presents the same symptoms.
9 Whether the other people immunized with the same lot of vaccine in the same
geographical area present the same symptoms.
9 Whether the other people immunized with the same lot of vaccine in the same
establishments on the same day do not present the same symptoms.
In any of the cases mentioned, corrective measures should be initiated immediately in
logistics, training, and supervision.

Related to the vaccine
This type of event implies a personal effect and is very rare (see Section 4). It is very
important to investigate each case, and while one expects the confirmation of a minimal
incidence of cases related to the vaccine the following can occur:
a)
The event occurred within the expected frequency range (see Section 4).
b)
The event was unexpected or occurred with unexpected frequency. In this case,
the following steps should be taken immediately:
Temporarily suspend the use of the product: the type or lot of vaccine/syringe that
is suspected.
Coordinate a reevaluation of the quality of the vaccine with the NRA and
communicate with the manufacturer, if necessary.
Arrange for the return of the vaccine, if appropriate.
Report the findings of the investigation to the Pan American Health Organization
so that the information is disseminated internationally.
9
9
9
9
3.- The investigation is in conclusive.
When causality cannot be determined, in addition to reporting the findings of the
investigation to the interested parties, the reason that no conclusion was drawn should be
indicated, along with whatever progress was made.
15
06.
Event Reduction during Vaccination Campaigns
The number of observed events is directly related to the number of administered doses; in
other words, if a vaccination campaign is being carried out with the application of a high
number of doses, it is to be expected that the number of events will also increase, but the
ratio (number of events/number of doses) should remain the same.
During a campaign, the following may occur:
-Apparent increase in ESAVI for one or more of the following reasons:
•
Application of a large number of doses of the vaccine over a short period, which
means that a greater number of ESAVI than expected may be registered. This can
cause concern among the people even though the adverse event rate remains the
same.
•
Both the health workers and the public tend to be more aware of ESAVI during
the campaigns, especially when injectable vaccines are used.
•
During a campaign there is a greater circulation of rumors, which can have a
negative impact on its later stages. Unlike what occurs with ESAVI registered
during normal vaccination programs, the campaign can be affected before there
has been sufficient time to counteract the rumors.
•
Campaigns can generate a lack of acceptance in given areas. ESAVI that occur
during a campaign can worsen an already negative situation and be utilized to
justify criticisms.
•
Vaccines are sometimes administered to broader age groups (usually to older
people) than during routine vaccination, and program personnel may have less
experience in treating the types of reactions or adverse events that these groups
may experience.
Real increase in ESAVI:
•
Personnel may feel pressured by the number of children to be vaccinated in a
short period and may try to simplify their work by not observing the customary
safety practices for the injections. This would increase the risk of adverse events
through program errors.
•
It is also possible that additional personal, unfamiliar with a given vaccine, are
used, thus increasing the program operation errors.
16
a. Measures to prevent ESAVI during campaigns
Strategies to reduce program errors
•
•
•
•
•
•
•
•
•
•
•
Use only quality vaccines approved by the United Nations or NRA and disposable
syringes for injectable vaccines.
Ensure adequate distribution of the dilutant and of the material injectable together
with the vaccine.
Reconstitute the vaccine only with the dilutant provided with the vaccine.
Utilize a disposable needle and a syringe of the size recommended for each type
of vaccine and for each vaccination.
Train health workers in the proper procedures for reconstituting lyophilized
vaccines and in appropriate techniques for administration.
Discard yellow fever vaccine one hour after reconstitution and measles vaccine at
the time recommended. For opened bottles, follow the policy recommended by
PAHO/WHO.
Plan the disposal of the injectable material so that it is risk-free.
DO NOT store drugs and other substances in the EPI refrigerator; it is to be used
exclusively for vaccines.
Specify the contraindications to the administration of the vaccine and the
precautions that the personnel in charge of its application in the field should take.
Train and supervise workers appropriately so that they observe safe injection
practices.
Investigate any program operation error so that it is not repeated.
Implementation of a fast and flexible surveillance system for ESAVI
In mass campaigns it is essential to perform some type of monitoring of ESAVI. If this is
not done, it is probable that word of these events will reach the ears of the public before
Ministry of Health personnel hear about them. If this occurs, the situation is very difficult
to control. The surveillance system should be simple, flexible, and fast. The planning
includes the following measures:
•
•
Deciding who will have general responsibility, who should be the coordinator,
and who the spokesperson.
Deciding what to report, how to report it, and what to investigate. Decide who
should receive the reports and who should participate in the investigation, if one is
needed.
It is necessary to make sure that the list of events is not complicated. It should
include:
–
–
–
all abscesses produced at the application site;
all deaths attributed to the vaccination;
all hospitalizations registered as a result of the vaccination;
17
–
•
•
•
•
•
•
07.
any serious or atypical fact attributable to the vaccination (or that, in
opinion of the personnel or the parents, are so attributable).
Training personnel in the events that can be expected and how handle them.
Developing speedy mechanisms for sending information on happenings in the
field to the person responsible for monitoring ESAVI (telephone or fax).
Analyzing the data promptly (this it does not necessarily imply a complex
analysis) and quickly taking the appropriate steps. A critical report should not end
up abandoned on some desk.
Providing weekly feedback to assure the personnel and the community that no
problem has occurred.
Considering the possibility of creating a committee that reviews ESAVI, analyzes
the cause of the reported events (it could include, for example, a neurologist, a
pediatrician, an immunologist, and a pathologist) and that can be convened as
needed. It is advisable that its members be official representatives of the most
important professional associations.
Monitoring the lots of all vaccines and the places where they were distributed in
the regional and national areas.
Management of Crisis Situations
a. What is a crisis?
In the context of ESAVI, a crisis is a situation in which a real or potential loss of
confidence in the vaccines or in the vaccination service occurs, precipitated by
information about an adverse event (real or supposed). Often, crises can be avoided
through foresight, care, and training. If managed properly, the crisis will strengthen the
program and boost public confidence.
ESAVI are unavoidable, but when the immunization program is well-organized they can
be minimized. Accordingly, it is necessary to draft plans to deal with each of them.
One ESAVI might be the death of three infants after routine measles vaccination,
administered by the same vaccinator in a single morning. Another might be the result of
the publication of medical research that involved proving how detrimental a given
vaccine is.
For some years there has been a continuous undercurrent of concern about the use of
vaccines, especially in infants. There are several reasons for this, including the high
educational level of parents in all countries who are better informed and have access to
material that presents arguments for and against vaccination. As the incidence of
preventable diseases is reduced through vaccination, parents may perceive that the risk
incurred in vaccinating their children is greater than the risk of contracting the disease.
Program operation errors are more likely and their occurrence leads to a decline in public
confidence in the EPI.
18
b. Why does a crisis arise?
A crisis can arise for reasons that are outside the direct control of the program (for
example, the publication of an article in the press). Or perhaps the information on a
program operation error has been poorly handled by a health worker or a political
spokesman. It can also be the result of lack of planning, of inadequate management of
relations with the media, of lack of public support, or of deficiencies in communication of
vaccination policies. Suddenly, the communications media develops a great interest in
this issue, and the health authorities find themselves having to respond to difficult
questions, before a country that listens and observes very carefully.
c. Four steps for the management of ESAVI and prevention of crises
What can a health authority do in the face of a crisis? Certain steps should be taken in
advance, notably:
1.
2.
3.
4.
Anticipate. Do not wait until a crisis occurs. Prepare for the unavoidable.
Train vaccination personnel at all levels to respond adequately.
Confirm all the facts before making any public statements.
Prepare a plan to react to a crisis when it occurs.
Anticipate
•
Determine who will be responsible for answering questions. This function should
be assigned to someone with authority so that people see clearly that high-level
personnel are taking charge.
•
Develop relationships with the media, especially with journalists specializing in
health issues. This should be done by supplying the media with information on
health in general. It is useful to provide concrete informative summaries on
anticipated events and the frequency with which they occur under normal
conditions. Thus, when in a report a specific event is announced along with its
frequency, the journalists will already have background material on it. Pay special
attention to relationships with well-disposed journalists, whose support can be
requested in a crisis.
•
Prepare pertinent questions and answers and informative summaries about
ESAVI.
•
Before a mass campaign begins, make list of the problems that can arise.
Distribute press releases before beginning the campaign; thus the press will know
the levels of ESAVI to be expected.
•
Establish accredited information channels by issuing public awareness messages
on health over the radio or in a health journal.
19
•
•
Seek technical assistance from a local public relations specialist or someone
similar, to learn how to manage ESAVI.
Make sure that there is a budget allotment for training, planning, and reacting to
crises.
Training
Train yourself and the other senior managers. Include staff members at the local levels to
acquaint them with the media. Attention should be paid to preparation of written material
and training for newspaper, radio, and television interviews. Raise awareness among the
staff about aspects of the target population and the importance of body language.
Verify the facts
•
As soon as information on an adverse incident is received, it is necessary to
determine what actually happened. This should be done by going to the source of
the information by the fastest means--by telephone, for example. Be careful with
second-hand reports; investigate to determine whether the source is credible.
•
Next, decide if the ESAVI is indeed that. Some events are the result of a longerterm process and to single one out may not be appropriate. For example, if a
woman complains that the hepatitis B vaccine has given her multiple sclerosis, it
is not a crisis, but requires a longer-term response. On the other hand, a call to
temporarily interrupt the use of the vaccine can indeed be a crisis.
•
One should also wonder whether the ESAVI has a simple scientific explanation, if
additional studies are needed, or if a similar event occurred in another country.
Plan the responses
•
•
•
•
•
•
•
•
Create a crisis working group in which representatives of the population
participate, if appropriate. Examine the legal, technical, and communication
aspects.
Issue a preliminary statement within a few hours. Communicate with receptive
journalists with whom a relationship already exists.
Establish a mechanism for communicating with journalists.
Launch a serious technical investigation and keep the press informed about the
progress made.
Designate the person who will be responsible.
If the incident is of great magnitude, call a press conference daily. Try to meet the
expectations of the media in every way possible.
Review your knowledge of relationships with the public information media if an
appreciable amount of time has passed since the last training.
Organize and herald support measures for the people affected--i.e., covering
expenditures or setting up a telephone consultation service, without
acknowledging any blame.
20
•
•
•
08.
Consider the possibility of eliciting the support of celebrities, a noted athlete, or
other well-known individuals who are willing to support vaccination publicly.
Conduct a rapid opinion poll.
Evaluate the event and assimilate the lessons it offers about how things could be
handled better the next time.
Communication and Information on the Safety of Vaccination and
Immunization
The immunization program should make an effort to improve the channels of
communication with the community and health workers, providing with all frankness and
accuracy essential and complete information on the investigations under way on the risks
of the vaccination. The messages should be disseminated quickly and address the
concerns of the population.
Educational materials that promote vaccination and point out its benefits and risks should
be available. Furthermore, workers in the health sector should be informed of events
caused by program operation errors and should receive training to avoid an increase in
ESAVI. During critical periods, such as vaccination campaigns and investigations in
progress, health workers should have easy access to data on the details of immunization
and should accurately and truthfully disseminate the information provided by the health
authority.
a. Relations with the communications media
The mass media play an important role in the public's perception of vaccination and can
have a positive or negative influence. Mass media support for vaccination, especially
after the announcement of an ESAVI, can depend to a large extent on the communication
skills of the health authorities. Statements and press conferences are useful tools in
orienting the interest of the media when an adverse event occurs. The basic principles
that apply are honesty and trust.
It is important to communicate with professional organizations, health professionals, and
local health workers, insofar as possible, before informing the communications media. It
is necessary to teach health workers how to address people's concerns about a particular
matter. If health professionals and health workers can calm the public with precise,
up-to-date information, damage to the program will be minimized.
The objective of this section is to promote an understanding of the media's orientation
and provide concrete information on how messages should be transmitted to help
improve the public's perception of vaccination.
b. What is the perspective of the mass media?
21
Understanding what the media desire with respect to a news item can help the health
authorities to provide information that meets their expectations, while presenting a clear,
positive view of vaccination. The media are especially interested in news that captures
the attention of the public and helps to sell more copies or to enlarge the radio or
television audience. One of the techniques utilized is to dramatize and personalize the
reporting. If the media are given inappropriate material, they may sometimes portray the
health services or staff that administer the vaccinations as indifferent, impersonal,
incompetent, and even dangerous.
It is relatively easy for some news to generate panic and anger about an incident that is
either not related to the vaccination (although it coincides with it) or is a program
operation error without serious repercussions. Furthermore, the media tend to report
several events, overlooking the fact that, in context, their frequency is very low. One
incident linked to vaccination by the media even though its cause is unknown can arouse
a great deal of fear. Given these circumstances, it is important to develop good
communication skills to avoid this type of unfortunate situation.
c. How to give an interview or a press conference
When an ESAVI arouses a great deal of media interest, it is advisable to hold a press
conference or to accede to a request for an interview. When all journalists have access to
the same information and none are excluded, they cannot give as much emphasis to that
news and it is more difficult for them to sensationalize it. A press conference is also more
effective when there is great interest on the part of the media, since it makes it possible to
transmit the message to many journalists all at once. It also gives the representatives of
other organizations an opportunity to voice support for vaccination and for the approach
used to investigate the problem. In some situations, obtaining support from certain
professional organizations helps to generate more confidence.
Media interest is usually greater in the initial stages, when relatively little is really known
about the events and their possible causes. In this context, rumors are very likely to
spread and cause enormous damage. It is prudent, therefore, to call a press conference
immediately, even though the available information may be very limited. This will
improve relations with journalists and keep them from circulating rumors. At the end of
the press conference, it is a good idea to inform journalists that in a few days, at most,
another press conference will be held and that detailed information on the facts and on
the investigation will be provided at that time. It is also advisable to maintain periodic
contact with the media, reporting on the progress made in the investigation and
concluding with a summary of the results and all the corrective action taken or
anticipated.
How to prepare a press release:
All the information to be conveyed in a press conference should be prepared well in
advance and included in a press release. It is necessary to include:
22
•
•
•
•
A full account of the facts (in terms that can be understood by people unfamiliar
with the health services or vaccination) set in the appropriate context (for
example, an isolated event, a coincidental event) to prevent the incident from
tainting the entire immunization program.
Information on whether the incident is currently happening and if new cases are
expected.
A summary of the steps taken or anticipated (depending on the situation, these can
range from a plan of action to a finished investigation).
The causes of the incident (if they have been identified with reasonable certainty
and are not just hypothetical) and the corrective action taken or planned.
How to prepare for a press conference
Before accepting an interview, find out what topics will be addressed at the press
conference and how the information will be used. Anticipate the questions and prepare
the answers. Preparation for a press conference includes:
•
•
•
-
Identifying the key messages that one wishes to convey.
Designating a spokesman.
Preparing a file of informational material for all the journalists and other
community leaders. This should consist of:
a concise press release containing all the essential information.
complementary background (for example, the advantages of vaccination).
a set of questions and answers that includes the questions that have already been
formulated or that may be posed by a concerned public.
The key messages in favor of immunization can include:
•
•
•
•
•
•
The effectiveness of vaccination in preventing disease has been welldemonstrated.
It is more hazardous not to vaccinate, because of the potential serious
complications of the disease. It is much safer to be vaccinated than to contract the
disease. The idea that they are the same or practically the same, which many try to
spread, is not correct.
Vaccines can cause reactions, but they are usually mild and disappear
spontaneously; very rarely do they lead to serious or long-term problems.
Vaccine-preventable diseases have left the memory of millions of dead or
disabled individuals before the introduction of vaccines, and without their
ongoing use that situation would return.
The safety of vaccines is of fundamental concern to the providers of vaccination
services, and any anomaly in this regard is investigated and corrected (hence the
advantages of establishing a solid mechanism to monitor the safety of vaccines).
The ESAVI is being investigated, but it is presumed to be coincidental or due to a
local problem (depending on the type of event); in the meantime, however, it is
necessary to continue with the vaccination program to protect the population from
the disease.
23
•
Steps are being taken in this regard.
d. Sixteen pieces of advice on style
Some practical advice on style and techniques for dealing with the media is given below:
•
•
•
•
•
•
•
•
•
•
•
•
•
Be sincere. Don't lie. If you don't know something, say so, but promise to look
into the matter. Be frank and open. You might say, “This is what happened; we
are dealing with it.” An attitude of this type is important in establishing a lasting
relationship with the media and is the basis for winning confidence about
vaccination. A lie or an attempt to conceal the truth can become bigger news than
the original event.
Be understanding. Convey an image of solidity, humanitarianism, and
competence with respect to yourself and the vaccination service.
Be responsible. Don't be defensive. Say, for example: “We are going to find out
whether the information is correct.” Nevertheless, accept the responsibility that is
yours and avoid blaming others.
Be sensitive. Hold a press conference a day, if needed, to address the concerns of
the public and the media. It can become an instrument for building a solid
relationship with them.
Remain calm in the face of uncertainty. You can say, “For the moment we don't,
but we have taken the necessary steps to find the answer to your question.”
Be aware of body language. Expressions, looks, gestures, and body positioning
have great significance.
Be positive. Whenever possible, describe the situation in positive terms. Avoid
negative, brusque, or contemptuous comments and use terms like vaccine safety
(which has a positive connotation) instead of adverse event. Employ a positive
turn of phrase. Just as the media can utilize a situation to present arguments
against vaccination, with a little interest and reflection the information on the
same situation can be used to promote a positive attitude toward vaccination. The
most negative initial communication with a journalist can be turned into an
advantage for the immunization program.
Be prepared, so that you can communicate the essential concepts. Prepare
beforehand. Know what you want to say and take the initiative in leading the
interview to the chosen terrain. Transmit the ideas that you want to convey. Think
beforehand about the difficult questions that might be posed and prepare your
responses to them.
Stay serious. Jokes can be disastrous. In any case, the subject is rarely amusing.
Be calm! Avoid extemporaneous remarks. Don't give information that has not
been requested and that can lead to awkward situations.
Be dynamic and maintain control of the interview.
Be nice... even when things get complicated! It will have an impact on the
audience if, in the face of provocation, you manage to rise above the situation. Do
not resort to sarcasm or something worse.
Be aware of your greatest vulnerabilities and be prepared to respond when asked
about them.
24
•
•
•
Don't stray from the questions you feel safe in answering.
“Steer” complicated subjects to firmer ground. If necessary, restate the question
in your own words.
Be clear. Avoid jargon. When talking about complex medical concepts, use
simple sentences. Give examples that are easy to understand, if they can clarify
your meaning.
e. Skills
Everyone who deals with the communications media should acquire the following skills:
•
Ability to communicate the concept of risk adequately.
•
Ability to convey complex concepts simply.
•
Interpersonal skills, such as the ability to express empathy.
•
Specific skills for the communications media, such as being able to handle
television interviews.
•
Ability to rapidly acquire and process pertinent information..
ESAVI can generally be avoided. Do everything possible, because they do not
happen if training is adequate. If in spite of everything a crisis occurs, make sure
that, through proper management, the problem evolves positively and results in the
strengthening of public confidence in vaccines.
25
09.
Summary of Vaccines, Diseases They Prevent, and Disease Effects
Vaccine
Disease
Sabin
(oral polio vaccine)
DTP
(diphtheria,
cough)
tetanus,
Poliomyelitis
Microorganism: Poliomyelitis virus
whooping
Diphtheria
Microorganism:
diphtheriae
Corynebacterium
Whooping cough
Microorganism: Bordetella pertussis.
Tetanus
Microorganism: Clostridium tetani.
DT
(diphtheria, tetanus)
TT
(tetanus toxoid)
MMR
(measles, mumps, rubella)
See the previous sections on
diphtheria and tetanus.
See the previous section on tetanus.
Measles
Microorganism: Measles virus.
Effects of the disease
Mild symptoms (fever, nausea,
vomiting) are presented in 4% to 8%
of infections; 1% to 2% of the
infections give rise to aseptic
meningitis; less than 1% result in
paralysis.
The case-fatality rate for the cases of
paralysis ranges from 2% to 10%.
The effects are related to the toxin.
The case-fatality rate is 5% to 10%
(mortality is higher in the young and
the elderly). Myocardiopathy and
neuritis/neuropathy. There are also
cutaneous and nasal forms of the
disease.
Highly contagious disease of the
respiratory tract (case rates of over
90% in contacts with unvaccinated
people).
The
characteristic
paroxismal cough with inspiratory
stridor gives the disease its name. It
can also lead to pneumonia,
convulsions, and encephalopathy.
Approximately 1 in 200 patients
under 6 months die. Approximately
200,000 to 300,000 deaths worldwide
are attributed to whooping cough.
The infection causes painful muscle
contractions, that begin in the neck
and the jaw (trismus) and then
progress to the trunk. For neonatal
tetanus, the case-fatality rates are
high (in cases with short incubation
periods, over 80%). The tetanus casefatality rates are specific to each
country and range from less than 1%
to 90%.
See the previous sections on
diphtheria and tetanus.
See the previous section on tetanus.
Highly contagious acute disease with
fever, conjunctivitis, runny nose,
cough, and Koplik spots. The
characteristic exanthema appears 3 to
7 days later. Complications can arise
through bacterial superinfection in
10% of the cases. The case-fatality
rate in the developed countries is
approximately 0.2%, and in the
developing countries, 3% to 5%.
Acute encephalitis occurs in 1 in
1,000 cases, and subacute sclerosing
panencephalitis (SSPE) as a late
complication (several years after the
infection) in 1 in 100,000 cases.
26
Mumps
Microorganism: Mumps virus
Rubella
Microorganism: Rubella virus.
Haemophilus influenzae type b (Hib)
Haemophilus influenzae infections
Microorganism:
Haemophilus
influenzae type b (Hib)
Hepatitis B
Hepatitis B infection
Microorganism: Hepatitis B virus
Yellow fever
Yellow fever
Microorganism: Yellow fever virus
Vector: Mosquito
BCG
Tuberculosis
Approximately 1 in every 200
children
contracts
encephalitis.
Nearly 2/3 of those infected present
edema of the salivary glands
(parotid). Orchitis (inflammation of
the testes) occurs in 1 in 5
postpubertal males. Sterility is an
uncommon complication. Deafness
can occur but is uncommon.
Approximately 50% of the cases are
subclinical. The infection causes a
mild febrile disorder with exanthema
and lymphadenopathy. Occasionally,
arthritis and arthralgias occur.
Encephalitis and thrombocytopenia
are uncommon complications.
Congenital rubella syndrome occurs
in approximately 90% of infants
infected during the first trimester of
pregnancy. The children are born
with congenital malformations, such
as deafness, cataracts, microcephaly,
mental retardation, heart defects, and
bone diseases, and pregnant women
run the risk of miscarriage.
Before the introduction of the
vaccine, Hib was the most common
bacterial cause of meningitis. The
meningitis case-fatality rate is about
5%. Approximately 10% to 15%
have neurological sequelae, and
severe deafness occurs in 15% to
20% of cases. Before the vaccine,
Hib was also the leading cause of
epiglottitis, whose case-fatality rate is
1%. It also causes induces cellulitis
and pneumonia.
It causes a broad range of disease
manifestations: fulminating fatal
hepatitis, clinical hepatitis with
jaundice, subacute disease with
symptoms,
and
nonspecific
asymptomatic
seroconversion.
Chronic hepatitis B infection occurs
in up to 30% of children infected
after birth and in 5% to 10% of older
children /adolescents. The acute
disease has a case-fatality rate of 1%
to 2%. The chronic infection can lead
to cirrhosis of the liver or to
hepatocellular carcinoma.
Around 15% of those infected
contract a serious disease with
several phases: acute, in remission,
and toxic. With the onset of the toxic
phase,
the
case-fatality
rate
approaches 50%. People immunized
naturally or by vaccination seem to
present a milder clinical disease. The
case-fatality rates in unimmunized
populations can exceed 50%.
It causes lung disease, meningitis,
27
(Bacillus
vaccine)
of
Calmette-Guérin
Microorganism:
tuberculosis.
Mycobacterium
Pneumococcal vaccine
(Streptococcus pneumoniae)
Pneumococcal disease
Microorganism:
Streptococcus
pneumoniae
Meningococcal vaccine
(Neisseria meningitidis)
Meningococcal disease
Microorganism:
meningitidis
Neisseria
and disseminated infection. The
infection is generally latent for long
periods and is reactivated in later
stages of life.
After the introduction of the vaccine
against H. influenzae type b,
pneumococci became one of the most
common
bacterial
causes
of
meningitis. Pneumococcal meningitis
case-fatality rates vary from 10 to
30%. This microorganism also causes
acute otitis media, pneumonia, and
other invasive diseases. Mortality
from the invasive diseases is high in
populations with chronic diseases and
with compromised immune systems
Since the introduction of the vaccine
against H. influenzae type b, this
organism has become one of the most
common causes of meningitis
(together
with
pneumococci).
Meningococcemia is another invasive
disorder caused by this bacterium.
The fulminating cases can present
purpura, disseminated intravascular
coagulation, shock, coma, or even
death.
28
10.
Bibliographic References
American Academy of Pediatrics. En: Peter G, (Ed.) 1997. Red Book: Report of the
Committee on Infectious Diseases. 24th ed. Elk Grove Village, IL: American Academy
of Pediatrics, 1997.
Centers for Disease Control and Prevention. Update: vaccine side effects, adverse
reactions, contraindications, and precautions-recommendations of the Advisory
Committee on Immunizations Practices (ACIP). MMWR 1996;45(No. RR-112).
Department of Health Welsh Office, Scottish Office Department of Health, DHSS
(Northern Ireland). En: Salisbury DM y Begg NT, (Ed.) Immunization against Infectious
Disease. Londres: HMSO, 1996.
Institute of Medicine (1994). Adverse Events Associated with Childhood Vaccines.
Washington, DC: National Academy Press.
Manual de vigilância epidemiológica dos eventos adversos após vacinação - Organizada
pela Coordenação de Imunizações de Auto-Suficiência em Imunobiológicos - Brasilia:
Ministério da Saúde. Fundação Nacional de Saúde, 1998.
National Advisory Committee on Immunization. Canadian Immunization Guide. 5th ed.
Ontario: Canadian Medical Association, 1998.
National Health and Medical Research Council, in conjunction with the National
Childhood Immunisation Program (an initiative of the Commonwealth Department of
Health and Family Services). En: Watson C, (Ed.) The Australian Immunisation
Handbook. 6th ed. Canberra: Australian Government Publishing Service, 1997.
Pan American Health Organization, Guidelines for Managing Immunization Safety
Concerns, junio, 2001.
World Health Organization, Expanded Program Immunization. Supplementary
information on vaccine safety, Part 1: “Field issues”, WHO/V&B/00.24, Geneva 2000.
World Health Organization, Expanded Program Immunization. Supplementary
information on vaccine safety, Part 2: “Background rates of adverse events
followingimmunization”, World Health Organization, WHO/V&B/00.36, Geneva 2000.
29